Twisted AMC & C&R Fees Gone Wrong!

VaCAP Board

VaCAP Board

Coalition of Appraisers in Virginia at Virginia Coalition of Appraiser Professionals
Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.
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Confused AMC Not Following Virginia C&R Fees Compliance Rules

This AMC is Just Wrong & Confused!

An AMC sent an appraiser the following email this morning:

“…..customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to:“

Wow are they confused about customary and reasonable fees! This is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers. Virginia Law mirrors the language in the TILA. They are essentially the same. The verbiage in the email sent to appraisers by this AMC is just WRONG!

The Virginia Real Estate Appraiser board attempted to make things easy for AMCs. On February 23, 2016 the Virginia Real Estate Appraiser Board adopted the United States Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fees Schedule as a presumption of compliance. This was a gift to the AMC’s, but I guess some just don’t want to accept it.

The Virginia Real Estate Appraiser Board created a Guidance Document for AMCs and appraisers to help understand the law. VaCAP sent a copy of the Guidance Document via email and US Mail to the address of record for each AMC licensed to operate in Virginia. As AMCs did not like this clear guidance, they began to twist things around, or just ignore the parts of the legislation they did not like.

As many were still confused, or trying to avoid paying appraisers a customary and reasonable fee, the Virginia Real Estate Appraiser Board published additional guidance on DPOR’s website. They in turn sent this additional clarification along with a copy of the original Guidance Document to each AMC and appraiser licensed to operate in Virginia.

The Virginia Real Estate Appraiser Board has gone out of its way to help the AMCs. It boggles the mind why some refuse to accept it!

And here we are today… The final rules have commentary associated with them explaining each and every provision of the Dodd-Frank Act including customary and reasonable compensation to fee appraisers. Even if you don’t like the rules, we all must follow them.

Image credit flickr - Russ Sanderlin
VaCAP Board

VaCAP Board

Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.

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36 Responses

  1. Mark Skapinetz on Facebook Mark Skapinetz on Facebook says:

    Hey. Go work for COESTER VMS and that delusional owner. He has his own way of setting fees and soon a fee calculator. Yep a 1004 FHA FOR UNDER 350? it’s a joke. The AMC model is broken and needs a new fix and fast. We are getting screwed as appraisers while AMC’s pad their pockets with as much money as they can.

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    • JC says:

      I’m with you Mark. Got one FHA for $325. Coester is one of the worst AMCs out there. Don’t get me started on Brian Coester. He’s a crook. His AMC has been sanctioned by several states for paying low fees and not paying what they owe. WILL NEVER WORK FOR THEM!

      StreetLinks Waterfront Appraisal order blast

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    • E J Brown says:

      Wow, $350, you’re lucky I get them from Coester here in GA for $225. Needless to say I have never done work for them.

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      • Mark Skapinetz on Facebook Mark Skapinetz on Facebook says:

        You need to print those order requests out and send them into the state board for investigation. I have and waiting on the board. We do have a C&R law here in GA NOW

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      • JC says:

        $225? Geez, who are the idiots taking these jobs? They’re the problem and the reason why these bottom of the barrel AMCs are still in business!

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        • Mark Skapinetz on Facebook Mark Skapinetz on Facebook says:

          It’s the “I need to put food on the table and support my family” people. They have no respect for the industry. Just want to do as many jobs as they can and most likely do a crap job at it. Sorry but there are many other better amc’s out there that pay WELL. COESTER, street links, ISGN, Imortgage, and more are garbage. They don’t care about quality or experience. They care about making them money. COESTER….. This is a company run by a guy fined by numerous states and as an appraiser was fined by the state of Maryland with the highest fine ever for pretty much a report that was proven to be incredibly inaccurate. It’s a shame that states allow this company to continue to do business within the state. Appraisers are being made a fool of by these companies. It’s sad.

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      • You also need to turn them into to FDIC complaints. (Make sure you have to complaint for appraisal fees) and OCC.

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      • Diana N. says:

        How about $270.00 in CT for a single family. What a joke.

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  2. GAPeach says:

    Why not name the AMC?

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  3. John Pratt says:

    CoesterVMS send me appraisal orders every week just like the one you have cited above. I never respond however I do enjoy seeing how ridiculous their request are. Many time they will call within a day or 2 with the same request, I am always polite to the caller, remember they are just the messenger and doing the job which they were hired to do. I have never accepted an assignment from them, I do not work for companies that operate like that. There are several other that are just like them. If all appraisers refused to accept assignment from them they would go out of business.

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    • Baggins - light years past form filling Baggins - light years past form filling says:

      You cannot negotiate with people who say what's mine is mine and what's yours is negotiable

      Well that’s professional and nice and all of that. I never accept the ‘it’s just my job’ argument, and immediately respond with some sort of ethics quote. There are a million of them, just pick one. My primary engagement criteria is ethic as that relates to duty.

      Ethics is knowing the difference between what you have a right to do and what is right to do

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  4. John Pratt says:

    Unfortunately in California the board here tells us they do not have the authority to enforce C & R fees. Some of the other AMCs that blast out appraisals with low fees are  Lres and Clear Capital.  I maintain a list of AMCs and a few Lender that I do not work for, for various reason, it now totals 20 companies.

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  5. Bill Johnson says:

    If anybody really cared (lenders, AMC’s, etc.), how hard would it be to say we need a USPAP compliant report and we pay at a rate equal to the VA schedule (Say $500). Per Dodd/Frank and the state of Virginia, ANY expanded scope of work requirements (above guidelines / 15 page engagement letters) should warrant higher fees. The cost approach might pay $50. Each additional comp above the mandated three might be $50 each. If my local carwash can breakdown and determine fees to the nearest dollar, and my local fast food joint can charge 10 cents for extra dipping sauces, then why are these extras (minutes to hours) for appraisers non-calculable? With state law, a competent and eager appraisal board, and a known and disclosed system to all parties, please appraisers of Virginia file by the thousands complaints of below C&R fees.

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  6. TOM D says:

    yea!!!! and $10 extra for each lash of the whip, minus the cost of bread and water that they advanced.  the few here may have escaped the plantation, but i hear the hounds.

    cruise of the damned going around in circles, but always fun to read the comments, freed man for the moment.

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  7. AMC’s want the lowest bidder nothing else

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  8. This is appraiser Pimping!!

    GET STARTED TODAY! 866.439.9546
    Appraiser Sign Up
    Welcome to AMC Links. Please fill out the information below to apply for approval on the AMC Links appraiser panel. Any questions may be directed to appraisersignup@amclinks.com. Thank you!

    Are you willing to accept Promotional Assignments? more info: ((Please answer YES if you are willing to accept single family 1004 and FHA assignments for a reduced fee during promotional campaigns for new clients. This is an exciting new opportunity to expand your business and gain preferred status for all AMC Linksn++ appraisal assignments. AMC Links may offer new clients a substantial discount during the 30-60 days of their sign-up. In most cases, you will receive 100% of the total appraisal fee we collect, and we will provide the management services for free or at a loss. Our promotional rate compensation to you will be approximately 65 -75% of current rates. This will be for new and underperforming AMC Links clients only and will not affect compensation status with current clients. This will be a time limited process and after 30-60 days we will change to a standard pricing structure similar to our existing client base and your compensation rate will also adjust accordingly. Those appraisers that participate in Promotional Assignments will be given priority status for future orders. As always, you will be notified of all promotional assignments and can accept or decline each one at the time they become available. If you are willing to participate and be placed on the Promotional Appraiser Assignment List please answer YES.))

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    • Baggins Baggins says:

      Dang. I’m running a special promotion right now. Double rate with variable due date. 

      Yet another instance of an amc probably taking a loss in one area to recover on those flat rate contracts in other areas. If this amc was not actually giving lenders discounts and was tricking the appraiser with a sales pitch without substance, they could really be in violations of multiple rules and even state and federal laws. It’s such a risky deal, why would they even offer that in the first place? Too much room for abuse. Yet more data which confirms that a direct consumer to appraiser fee relationship is necessary.

      “If anyone wants to save the borrower a dollar or a day, they’re free to do so from their side of the desk. As an appraiser, I cannot afford to leverage or offer any discounts what so ever.”

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  9. Baggins Baggins says:

    Jodi, just dare to go look at the amc’s web sites and such. Many of these guys offer ‘profit sharing’ return to the lenders.

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  10. TruthBeTold says:

    I’m so excited I had to tell someone. Here in L.A. for the past two weeks I’ve had the traditional low fee AMC clients begging me to take work and offering to pay whatever I want. Just got a call from AMC who last sent an appraisal assignment to me where the value range was 5,000,000 and the fee offered was $275.00 To all appraisers; this is about supply and demand. Do not go out and corral a bunch of people to be new appraisers. Your additional income will be short lived. Keep the supply/demand in balance. Your Worth, Livelihood and Value depends on it!

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    • Retired Appraiser Retired Appraiser says:

      Anyone that’s nuts enough to appraise a $5,000,000 home for a $275 fee needs to do their “profession” a favor and just kill themselves. If you don’t have the guts to do your colleagues that little favor and you’re way short on intelligence consider over the road trucking. You’ll make twice the money for 1/20th the effort and 1/1000th the liability.

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    • Baggins Baggins says:

      We’re approaching the time when there are literally more vendor managers than there are vendors themselves.  Hang tough.

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  11. A Creed is what you already believe – it is what you are. An affirmation is what you want the universe to give you; a creed is what you are giving to the universe.

    The AMC Creed for Appraisers:
    More Work, Less Time, Half Pay
    And You’ll have another order the next day!
    Question Why!
    And We will say Good Bye!
    If you keep saying NO!
    There will be no more AMC’s for you to GO!
    There are plenty more Appraisers that will Bend Over
    And spread it wide so Move Over Grover
    There is more behind you willing to take our scraps
    So we can meet our Caps
    Once the caps are met we are in Line
    For a big fat BONUS that will be MINE!
    More Work, Less Time, Half Pay
    Makes the $8.00 an hour email nagging, phone pushing a Happy Day!

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    • Retired Appraiser Retired Appraiser says:

      After the universe gave appraisers the reaming of a lifetime I happily sent my license back with the following notation on the package:

      RETURN TO SENDER
      c/o Roscoe Universe
      1 Cosmos Blvd
      Infinity

      P.S. Please File This License Away Where The Stars Don’t Shine

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      • Wayne says:

        hey…my retired appraiser friend. I see this silly business much different than most of my fellow appraisers. Our little office does not accept any assignment from any AMC. We accept no FHA work. Our VA work has been reduced to just one small county. We refuse to accept any assignment from any mortgage broker. Well…that should just about put our asses out of business. But Gee…we turn down several requests each and every day!  Why not promote your business to the point that you no longer provide the fees for appraisal parasites to rip you off? I am just one of two people in a small appraisal office. GEE…there is absolutely NO way that I could possibly take on all the appraisal work that is being offered to me. If you are working for AMCs or national appraisal companies….you are cheating yourself and your family.

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  12. I received an order via appraisalport. My fee $259. AMC fee $181. 41%

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    • Baggins Baggins says:

      Primary client struggling for fulfillment. Sending some through amc’s, rather than beef up staff. They had to make tough choices but are keeping their in house division open.

      Landed a batch set of orders for the first time, in a long time. All through direct side, no amc’s. $650 across the board. Probably a similar fee they’d pay over all if utilizing amc services. Well dang son, it’s about time. And thanks again to the better half of this industry.

      It’s like Trump’s words are already resonating true. I’m not used to winning this much, slow it down. Ha! Meanwhile, most amc’s in the area are taking losses on flat rate engagements and can’t wait until the day they turn down these fees again. You win some and you lose some but the important consideration is who’s got the highest standard base fees you can count on in lean times?

      I won’t allow my negotiations to cause harm to other appraisers, which is why I refuse to quote companies that do not have direct appraiser to consumer sort of fee relationships (most of the time). Flat rate is a bust. Prefer the guys who play fair all the time not just when they have to, and look at the big picture.

      Jodi, that’s so corny. I tell them the billing is non negotiable metric based. Always round up, rending that fee proposal to me as $300. Not enough of course, but as a rule of thumb always round up to the next metric fifty.

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  13. John Pratt says:

    Jodi, I don’t know where you live, I live in Northern California and am semi retired. In the last month and half I have taken 12 orders, total fee  $7,900 that is an average of $658/ ea. Two of these were Mutli-family, 4-units for $1,000.ea. They were copies of each other and next door to each other and I completed them in 2 days after I inspected them. All of these were in the city limits of where I live. I can not imagine even responding to a request that came in at $259. You could make more money cleaning houses. This kind of business is available, you need to set yourself up to take advantage of this kind of business. I think you need some business guidance.

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    • John Most of the AMC’s in South Eastern VA pay between $238.00 – $245.00 There are only a few AMC’s that pay $350.00 – $360.00 max for an 1004MC. There is no negotiating with these AMC’s either. Appraisers have to sign their contracts they cannot negotiate a contract. I thought being an Independant Appraiser aka Independant Contractor meant to negotiate a contract like a lawyer, Builder, tradesman, or other contractor. But that is not the way it is. If you don’t agree with their contract then you don’t sign up. If you don’t agree then YOU DON’T WORK! There is not negotiating a fee even when the subject is waterfront, lake front, new construction, with 5+ acres, located beside a school or beside commercial properties, which all take more time to find and drive the comparable properties to make sure they are comparables and not to mentions all the extra stipulations that they and the lender puts on the Appraisers that is more liability. Also, I am tired of AMC’s treating me like an EMPLOYEE instead of Independant Contractor like the IRS, Court of Pennsylvania. This list includes but is not limited too: Streetlinks, MCS Valuations, Corelogic, Allstate Appraisal, Nations Valuations Services,and National Property & Appraisal Services to name a few. Yes I have named them because this year I have only completed 15 Appraisals all year because when I quote a higher fee I get the standard removal of order because the bottom feeders have bid lower in the mass text or e-mails. I am fed up and ready to quit! AMC chock up another one that has left the profession. Do the math 13 X 245 = 3430 2x 350 = 700 = my grand total wages for the year is $4130.00. That is not enough to pay for my computer access and liability insurance. I can make $50,000 being an Admin Assistant like my friends with less liability, more fun and a great 401. It is a shame what has happened ot the Profession. Won’t everyone consider filing a complaint. https://ask.fdic.gov/FDICInteragencyForm/

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      • Baggins Baggins says:

        Keep applying, they don’t all operate that way. You named the big box ones, but some of the boutique amc’s are nicer to work with, with better ethic where they are fair with appraisers. Better than that is other standardized work like hud mm reo, fnma reo division, various direct lender, etc. Broad exposure is key to leveraging the same principals of substitution that drive the fees down, to drive them up instead. But yeah, I hung on for a decade before the discounters relented. It’s not a pretty or appealing picture and is a gamble. In the future, discounters will stress my position again when the volume relents, which is why I form alliances with distributors who pay acceptable minimums regardless of demand climate. A massive industry wide correction of amc distribution process is in the works. It’s easy to spot the dangerous amc’s, they always grade you instead of building parternships. My direct guy right now is subbing to amc’s, because he can’t find appraisers to sign up. Sad, because those appraisers did not know how to identify the difference between direct and amc, and subsequently actually accept discount work through amc’s, when the direct distributor would readily accept them on panel. 450 minimum all day long. That’s how it goes though, those amc’s drain all your time with the horse and carrot routine. Appraisers quick to sign up with companies without research get the short end of the stick. I’ve got 4 long drawers of legal cabs, with all the amc’s and direct distributors over 10 years. Just keep moving down the line. If you’re substitutable, so are they.

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      • Wayne says:

        Why do you do this?

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        • Baggins Baggins says:

          Wayne, I don’t know. Just appreciate the breathing room which comes with choice. I’m going to give up on this lecture. Bidding is code word for actively asking competing appraisers to undercut each other.

          It’s been quite fun, to instead of providing a ‘competitive bid’, instead turn the tables and turn the call into an immediate sales opportunity. “What’s the maximum fee you could assign this to me right now for?” And that’s where the rubber meets the road. They either can assign and have pre approval, or they don’t and may not even have the order yet, as lenders can tease multiple amc’s for best quotes at once. Sometimes they have to get individual approval for all quotes from lenders. Some of them can assign right there, and with such a question, you can identify their margins and operational relief room. I make decisions based on those figures too. The market is the consumer charge. How that splits up is largely dependent on the negotiations. In identifying an amc whom actually has the trust of lenders and can make independent decisions, then you can work batch deals. Let’s go 1 at 550 or 5 at 450. Whatever, I’m busy. C&R is a myth, like chasing dragon. The reason being is lenders are not affixed with base consumer charges like they used to be, and if they try to be, are typically working with antiquated irrelevant static charge tables. True C&R is sliding on scale, with a rather infinite scale of possible charge consideration, as broad as the valuation services request might be.

          Specifically page 9.

          https://www.fdic.gov/regulations/laws/federal/2010/10NoticeDec10.pdf

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      • Baggins Baggins says:

        Jodi, you’ll want to check out this link.

        Colorado legislation on amc regulation:

        Prohibited AMC activities:

        12-61-710.5. Appraisal management companies – prohibited activities –
        REQUIRING AN APPRAISER TO INDEMNIFY THE APPRAISAL MANAGEMENT COMPANY AGAINST LIABILITY, DAMAGES, LOSSES, OR CLAIMS OTHER THAN THOSE ARISING OUT OF THE SERVICES PERFORMED BY THE APPRAISER, INCLUDING PERFORMANCE OR NONPERFORMANCE OF THE APPRAISERS DUTIES AND OBLIGATIONS, WHETHER AS A RESULT OF NEGLIGENCE OR WILLFUL MISCONDUCT

        That one is a godsend. As of day 1 that was passed, I never had to agree to anything other than sow, to get orders. If your state does not have that vital inclusion, that one is worth mobilizing for.

        FAILING TO DISCLOSE TO A CLIENT THE FEE AMOUNT PAID TO THE APPRAISER HIRED OR ENGAGED TO COMPLETE THE APPRAISAL UPON COMPLETION OF THE ASSIGNMENT FAILING TO DISCLOSE TO THE APPRAISER THE FEE AMOUNT PAID TO THE APPRAISAL MANAGEMENT COMPANY BY THE CLIENT AT THE TIME OF ENGAGEMENT; OR

        And same thing for that one. If the appraisal problem is concealed fees, the solution is a requirement to state fees clearly. Some amc’s are still in violation of this request, and apparently appraisers are not holding them to the fire. But in CO at least, I get to know the amc rake, and I get to disclose my fee boldly within the report. If I flip an amc report without disclosing me fee, that is a violation. That one also set the record straight and although not verified officially, I think that had a very strong influence on stopping undercutters aggressive chop down of fees. They knew that during review, they’d get ate alive when appraisers learned their fees were downward of 175 per order. My how the tables have turned in the few short years since CO passed those regs….

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Twisted AMC & C&R Fees Gone Wrong!

by VaCAP Board time to read: 2 min
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